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Expert Analysis

Cybersecurity Considerations For CFTC Intermediaries

Law360, New York (March 22, 2016, 10:22 AM EDT) -- It is essential for commodity pool operators, commodity trading advisers, futures commission merchants, retail foreign exchange dealers, introducing brokers, major swap participants and swap dealers that are National Futures Association member firms (together "CFTC intermediaries") to develop, implement and enforce a cybersecurity program. Although some CFTC Intermediaries already have a compliant cybersecurity program in place, those that do not may find the task daunting as they assess how to develop and implement a cybersecurity program that satisfies the guidance and myriad requirements to which they are now subject....

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